Tax

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EU will propose minimum tax legislation if G20 reaches deal, commissioner says
mnetax.com Jun 14, 2021
The European Commission will propose legislation to implement an international agreement on a global minimum corporate tax to ensure its uniform application within the EU, according to June 14 comments from European Commissioner for Economy Paolo...
Biden tax plan sets aside money for R&D incentives, but details lacking
mnetax.com Jun 9, 2021
The Biden Administration proposes to enhance incentives for research and development (R&D) using revenue repurposed from the proposed repeal of the deduction for foreign-derived intangible income (FDII), according to the President’s tax plan...
G7 tax breakthrough sets stage for G20 talks in July, issues remain
mnetax.com Jun 7, 2021
G7 finance ministers reached a momentous agreement on June 5 on a global corporate minimum tax and changes to the allocation of taxing rights between nations. The specific details of this agreement will be the presumptive starting point for formal...
Coca-Cola says tax court erred in transfer pricing dispute, seeks reconsideration
mnetax.com Jun 7, 2021
The Coca-Cola Company on June 2 asked the US Tax Court to reconsider and set aside its November 2020 transfer pricing decision, in which it determined that Coca-Cola’s US income should be increased by about USD 9 billion, according to a motion...
Greece enacts corporate tax rate reduction, other support measures
mnetax.com Jun 7, 2021
The Greek government has retroactively reduced the corporate income tax rate, suspended the imposition of the special solidarity contribution (SSC), and introduced other support measures through Law 4799/2021, published in the Official Gazette on...
Australia budget includes tax changes affecting foreign investors
mnetax.com Jun 7, 2021
The Australian Treasurer, the Hon. Josh Frydenberg delivered Australia’s 2021–22 Federal Budget on 11 May. It was targeted to provide a significant economic stimulus and included a number of tax measures. Those most relevant to foreign investors...
Singapore declines to limit tax on imported low-value goods
mnetax.com Jun 2, 2021
The Inland Revenue Authority of Singapore (IRAS) on May 28 announced that it will not adopt several requested changes to the scope of the tax on imported low-value goods, provided for in draft e-Tax Guides “Taxing imported low-value goods by way of...
EU reaches agreement on public country-by-country tax reporting
mnetax.com Jun 2, 2021
Negotiating teams from the European Council and European Parliament reached an agreement on June 1 on a proposed directive that would require public disclosure of country-by-country tax information by certain large multinational enterprises...
Kenya tax bill alters permanent establishment definition, increases transfer pricing reporting requirements
mnetax.com Jun 2, 2021
Kenya’s Finance Bill 2021, published 5 May and tabled in the Kenyan legislature on 11 May, includes a new “permanent establishment” definition, country-by-country reporting requirement, and new rules for determining “control” among related...
US Treasury ‘Green Book’ details Biden’s international tax plans
mnetax.com May 28, 2021
The US Treasury’s Green Book, released today alongside President Biden’s FY 2022 Budget, outlines the specific tax provisions that the Administration seeks to enact this year, including significant proposals for overhauling the international tax...
Argentina issues pandemic-related transfer pricing relief, guidance
mnetax.com May 27, 2021
On April 30, Argentina’s tax agency announced that it will extend for a period of three months the deadlines to submit the transfer pricing documentation for fiscal years ending December 31, 2020, through December 31, 2021. So, for fiscal year...
Hungary, Ireland, UK reiterate resistance to global minimum tax while Germany remains optimistic
mnetax.com May 26, 2021
Hungary, Ireland, and UK officials have again warned that their countries will not accept the global minimum corporate tax sought under the OECD’s Pillar 2 talks. Hungarian Finance Ministry state secretary András Tállai, in comments published May...
UK R&D tax incentives need overhaul to improve effectiveness, study concludes
mnetax.com May 26, 2021
The UK’s research and development (R&D) tax incentive policies have generated a poor return in terms of increased R&D investments, but there are ways to make the incentives more effective while saving taxpayer money, according to a study published...
Japan enacts corporate, income, inheritance tax reforms
mnetax.com May 26, 2021
Reforms to Japan’s corporate tax, income tax, and inheritance tax, and new laws aimed at removing obstacles for Japanese asset management companies to appoint foreign fund managers were passed by the Diet on 26 March and enacted into law the same...
US Senate Finance Committee to consider overhauling energy tax code
mnetax.com May 25, 2021
The US Senate Finance Committee is set on May 26 to consider the Clean Energy For America Act, sponsored by Chairman Ron Wyden (D-OR), which would eliminate a number of temporary tax credits and replace them with emissions-based, technology-neutral...
EU consults on measures to combat use of shell companies to avoid taxes
mnetax.com May 24, 2021
A new European Commission initiative launched May 20 is exploring ways to fight the continued use of shell companies, i.e., entities with little or no economic substance, in cross-border arrangements for purposes of avoiding taxes. The Commission...
G7 reportedly close to deal on new rules for taxing multinationals
mnetax.com May 24, 2021
The G7 group of leading economies is getting close to an agreement to shake up the global rules on the taxation of multinational businesses, according to May 24 articles published in the Financial Times (subscription required) and Irish Times....
The EU Commission’s objections to Amazon’s transfer pricing approach
mnetax.com May 24, 2021
The General Court of the European Union on May 12 ruled that the European Commission failed to establish that Luxembourg’s tax treatment of Amazon violated EU state aid law. The decision notes the transfer pricing approach adopted by Amazon for its...
BEPS multilateral tax treaty signatories provide interpretation guidelines
mnetax.com May 20, 2021
Issues relating to the interpretation and implementation of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) should be resolved under several guiding principles, according to an...
The UN transfer pricing manual’s guidance on IP valuation and royalty rates
mnetax.com May 19, 2021
The latest edition of the United Nations Practical Manual on Transfer Pricing for Developing Countries, released April 27, includes some useful observations on the nature of intangible assets, their creation, and the key issue of ownership among...
Australian draft guidance clarifies tax compliance for intangibles arrangements
mnetax.com May 19, 2021
The Australian Taxation Office set out its compliance approach to various international arrangements relating to intangible assets and the associated tax compliance risks in a draft practical compliance guideline on intangible arrangements...
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